Overview

The Centers for Medicare & Medicaid Services (“CMS”) is launching a new model aimed at improving the quality of care and health outcomes for individuals with behavioral health (“BH”) problems. The model, announced on January 18, 2024, and styled as the Innovation in Behavioral Health (“IBH”) model, will support community-based BH practices so that BH providers will work as a care-management team and coordinate with other providers. State Medicaid agencies will lead IBH with the goal of aligning payment between both Medicaid and Medicare. The IBH model is expected to begin in fall 2024 and run foreight years.

How Will IBH Work?

CMS will select eight states to participate in the IBH model through a Notice of Funding Opportunity that is expected to be released in spring 2024. The practice participants within the eight states will be eligible to participate in both the Medicare and Medicaid payment models.

Examples of community-based BH practices eligible to participate in the IBH are community mental health centers, public or private practices, and opioid treatment programs. In order to take part in the IBH model, these practice participants must be licensed in their selected state to deliver mental health or substance abuse disorder services, meet state Medicaid provider enrollment requirements and be eligible for Medicaid reimbursement, and provide outpatient mental health and/or substance abuse disorder services to adult Medicaid beneficiaries with moderate to severe BH conditions.

The role of the state Medicaid agency will include the following:

• Develop and enhance infrastructure to support practice participants.
• Work with Medicaid managed care organizations (“MCOs”) or other intermediary partners to implement IBH and recruit practice participants.
• Partner with its state’s agency for mental health and/or substance abuse disorders to develop clinical policies.
• Develop a Medicaid alternative payment model that aligns with IBH.
• Convene relevant stakeholders in IBH development and implementation.
• Collect, analyze, and share data with CMS.

The role of Medicare will include the following:

• Provide funding to practice participants who participate in Medicare for health IT investments and practice transformation.
• Provide payments for initial and ongoing screening, assessment, coordination for behavioral and physical conditions, and screening and referral for health-related social needs based on an integration support payment model. An integration support payment model is a prospective, risk adjusted Medicare per member-per-month payment model.
• Provide payment based on performance to incentivize improving patient outcomes.

Medicare practice participants will also receive funding from CMS to implement health IT infrastructure capacity, telehealth tools, and practice transformation activities. States will provide funding for similar activities for Medicaid-only patients.

Who Are the Intended Beneficiaries?

Adults who are enrolled in Medicaid or Medicare or dual eligible adults who are experiencing health conditions and receiving care from a participating practice in one of the designated states will be the beneficiaries of IBH.

How Will Practice Participants Deliver Care?

The goal of the IBH model is to equip BH practices to engage in primary care services and meet health-related social needs of patients. Under the IBH model, practice participants will need to screen for behavioral health, physical health, and social needs in patients; plan how to treat physical and behavioral conditions or refer patients to physical health care; monitor behavioral health conditions and physical health conditions; and make adjustments to patients’ care plans. Care under the model will ultimately be provided by interprofessional teams that develop care that reflects the behavioral, physical, and health-related social needs of the patients. The care teams should include people with physical health expertise and care management staff.

Health Equity

Practice participants are also required to create a health equity plan (“HEP”) to address the needs of the population they serve. According to CMS, HEPs should address the steps that practice participants will take to address health disparities that impact the population that they serve. Practice participants will also screen, refer, and follow-up for health-related social needs to increase health equity.

Next Steps

CMS has indicated that further details on how states can participate are expected to be released in early 2024 in conjunction with the release of the Notice of Funding Opportunity.